Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Reassessment u/s 147 - The full and true disclosure of the assessee is not in doubt - The ‘recording of reasons’ is mechanical and robotic and the mandate u/s 147 has not been complied with - It was incumbent upon the AO to have had independent ‘reasons to believe’ that there is escapement of tax, even if the initial nudge did emanate from the audit department - reassessment quashed
Reassessment u/s 147 - The full and true disclosure of the assessee is not in doubt - The ‘recording of reasons’ is mechanical and robotic and the mandate u/s 147 has not been complied with - It was incumbent upon the AO to have had independent ‘reasons to believe’ that there is escapement of tax, even if the initial nudge did emanate from the audit department - reassessment quashed
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